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Cannavec Skills / Jurisdiction comparison

Compare cannabis rules, side by side.

6 jurisdictions. Government sources only. Every material claim dated and linked.

Compare
3/4
Quick topics

Downloads include the topics shown, source links and verification dates.

Source review dated 17 Aug 2026. Confirm current rules before acting.

10 of 10 topics shown

Medical status

Is there a lawful medical route?

LAW

Canada

Reviewed 17 Aug 2026 · Federal + local

Legal

A federal medical-access framework operates under the Cannabis Act and Cannabis Regulations.

RegulatorMedical frameworkReg.Cannabis Regulations

Germany

Reviewed 17 Aug 2026 · Federal

Legal

Medical cannabis may be prescribed by a physician and dispensed by a pharmacy.

LawMedCanG §3OfficialMedical FAQOfficialCannabis Act FAQ

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Legal, tightly controlled

Cannabis-based products for medicinal use (CBPMs) have a lawful prescription route.

Reg.CBPM RegulationsOfficialCBPM reschedulingOfficialNorthern Ireland access

Adult-use status

What non-medical possession or access is lawful?

LAW

Canada

Reviewed 17 Aug 2026 · Federal + local

Legal

Adults of the applicable provincial or territorial legal age may buy and possess legal cannabis.

The federal public-possession limit is 30 g of dried cannabis or its equivalent; minimum age and retail rules vary by province or territory.

LawCannabis ActOfficialProvincial rules

Germany

Reviewed 17 Aug 2026 · Federal

Limited legal access

Limited non-commercial possession, home cultivation and cultivation-association access are lawful for adults.

This is not a general commercial retail market: possession is capped at 25 g in public and 50 g at home; home cultivation is capped at three plants.

LawKCanGOfficialCannabis Act FAQ

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Illegal

Non-medical cannabis remains illegal.

Cannabis remains a Class B controlled drug; unauthorized possession, supply and cultivation remain offences.

OfficialCBPM reschedulingOfficialControl framework

Control & scheduling

Which legal control framework applies?

LAW

Canada

Reviewed 17 Aug 2026 · Federal + local

Cannabis is federally controlled through the Cannabis Act and Cannabis Regulations.

That framework separately regulates cannabis products and prescription drugs containing cannabis.

Reg.Cannabis RegulationsRegulatorProduct rules

Germany

Reviewed 17 Aug 2026 · Federal

Cannabis and non-synthetic THC are no longer narcotics under the Narcotics Act.

Non-medical cannabis is governed by KCanG; medical cannabis is governed by MedCanG.

OfficialCannabis Act FAQOfficialMedical FAQLawKCanG

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Cannabis is Class B and generally Schedule 1; qualifying CBPMs are Schedule 2.

Products outside the legal CBPM definition remain Schedule 1 unless separately scheduled or authorized.

OfficialControl frameworkOfficialCBPM rescheduling

Medical access

How does a patient obtain a lawful product?

REGULATION

Canada

Reviewed 17 Aug 2026 · Federal + local

Obtain a medical document, then register with a federally licensed medical seller.

A patient may instead register with Health Canada to produce personally or designate a producer.

RegulatorMedical accessRegulatorMedical framework

Germany

Reviewed 17 Aug 2026 · Federal

A physician prescribes; an operating pharmacy dispenses against that prescription.

Medical cannabis no longer requires the former narcotic-drug legal classification.

LawMedCanG §3OfficialMedical FAQ

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Licensed cannabis medicines follow their marketing authorization; unlicensed CBPMs require specialist prescribing.

Public-system access is devolved. NHS England and NHS Scotland both describe routine access as limited to a small number of patients and products.

OfficialCBPM reschedulingOfficialNHS England accessOfficialNHS Scotland accessOfficialNorthern Ireland access

Who can access

Who may use the medical or adult-use pathway?

REGULATION

Canada

Reviewed 17 Aug 2026 · Federal + local

A health-care practitioner must authorize use; clients of a federal medical seller must ordinarily reside in Canada.

A responsible adult may act for a child, older adult, or person with a serious impairment.

RegulatorMedical accessReg.Cannabis Regulations

Germany

Reviewed 17 Aug 2026 · Federal

The federal prescribing provision does not set a closed list of qualifying conditions.

Treatment is a physician decision; dentists and veterinarians may not prescribe medical cannabis.

Important scope note

Coverage or reimbursement rules are separate from the legal ability to prescribe.

LawMedCanG §3

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

A specialist may consider an unlicensed CBPM when clinically appropriate; licensed products have product-specific indications.

NHS England guidance highlights severe epilepsy, chemotherapy-related nausea and multiple-sclerosis spasticity for specific medicines; devolved services publish their own access guidance.

OfficialCBPM reschedulingOfficialNHS England accessOfficialNHS Scotland accessOfficialNorthern Ireland access

Prescription

What authorization must the patient have?

REGULATION

Canada

Reviewed 17 Aug 2026 · Federal + local

The federal medical route uses a signed medical document rather than an ordinary retail prescription.

The document states the authorized daily amount and period of use and supports registration.

RegulatorMedical accessReg.Cannabis Regulations

Germany

Reviewed 17 Aug 2026 · Federal

A physician prescription is required; pharmacies may dispense only on presentation of it.

A government bill would add personal-contact requirements and restrict mail-order supply. It remains a proposal and is not treated here as current MedCanG law.

Important scope note

Proposed rules are shown only as a watch item; the consolidated statute controls the current-law summary.

LawMedCanG §3OfficialPending MedCanG bill

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Unlicensed CBPMs must be prescribed by a doctor on the GMC specialist register.

A marketing-authorized medicinal product is not subject to that same additional specialist-only route merely because it is cannabis-based.

OfficialCBPM rescheduling

Visitor & import

Can a visitor bring prescribed cannabis across the border?

LAW / POLICY

Canada

Reviewed 17 Aug 2026 · Federal + local

Normally prohibited

Do not cross the Canadian border with cannabis, including medical cannabis or CBD, without a Health Canada exemption.

A medical prescription is not Health Canada authorization. CBSA says a permit or exemption is required even when the product is lawful where the trip began.

OfficialBorder rulesOfficial2026 border notice

Germany

Reviewed 17 Aug 2026 · Federal

Confirm before travel

Do not infer a simple visitor exemption from Germany's domestic legalization.

BfArM says certified travel documentation is generally still needed because international controls and other countries' rules continue to apply.

Official evidence unclear

The official page is travel guidance, not a blanket authorization for every foreign product entering Germany.

RegulatorTravel guidance

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Conditional

A non-UK resident may carry up to a three-month supply of a Schedule 2–4 Part I medicinal product that was lawfully prescribed and dispensed.

Carry it on your person with a clinician letter. Schedule 1 products cannot normally enter without a licence, so product classification matters.

OfficialBorder rules

Permitted forms

Which product forms are within the regulated pathway?

REGULATION

Canada

Reviewed 17 Aug 2026 · Federal + local

Federal medical sellers may supply fresh or dried cannabis, edibles, topicals and extracts.

Plants and seeds also support authorized production routes. These cannabis products are not, merely by using the medical pathway, Health Canada-authorized treatments for a disease or symptom.

RegulatorMedical accessRegulatorProduct rulesRegulatorProduct evidence

Germany

Reviewed 17 Aug 2026 · Federal

Medical products include standardized dried flower or extracts and medicines containing dronabinol or nabilone.

Exact preparation availability depends on the prescription and pharmacy supply. Adult-use associations may distribute only marijuana or hashish in pure form, not edibles.

LawMedCanG §3OfficialMedical FAQOfficialCannabis Act FAQ

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Licensed examples include an oral CBD liquid, a synthetic cannabinoid capsule and a THC/CBD mouth spray.

Unlicensed CBPMs may take other medicinal forms, but smoking cannabis or a CBPM remains prohibited.

OfficialNHS England accessOfficialCBPM rescheduling

Driving

Does lawful access change drug-driving rules?

LAW / POLICY

Canada

Reviewed 17 Aug 2026 · Federal + local

Lawful possession or medical authorization does not permit cannabis-impaired driving.

The Criminal Code prohibits driving while impaired to any degree and creates separate offences at federally prescribed blood-THC concentrations within two hours of driving.

LawImpaired-driving lawReg.THC limits

Germany

Reviewed 17 Aug 2026 · Federal

A 3.5 ng/mL blood-serum THC threshold applies to the road-traffic offence.

Section 24a excludes THC arising from proper use of medicine prescribed for a specific case. That exception does not authorize driving while actually unfit under the separate criminal impairment rule.

LawStVG §24aLawStGB §316

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

A prescription does not permit driving while impaired.

In England, Scotland and Wales, a medical defence may apply to the specified-drug limit offence when medicine was lawfully supplied and taken as directed, but not to impairment. Northern Ireland applies a separate impairment regime.

Important scope note

The per-se drug-limit and medical-defence guidance cited here applies to Great Britain, not Northern Ireland.

OfficialGB driving rulesOfficialNI driving rules

Practical implications

What changes the real-world ability to access or use cannabis?

PRACTICAL ACCESS

Canada

Reviewed 17 Aug 2026 · Federal + local

Medical registration is resident-based; authorized provincial retail is the practical route for eligible adult visitors already inside Canada.

Public-use and home-cultivation rules can change by province, territory and municipality. Authorized medical patients have separate public-possession documentation and limits.

Reg.Cannabis RegulationsRegulatorMedical frameworkOfficialProvincial rules

Germany

Reviewed 17 Aug 2026 · Federal

There are no general adult-use shops; lawful supply is limited to home grow and non-commercial cultivation associations.

Home cultivation and association membership require at least six months' residence or habitual abode. Public consumption is restricted around minors, youth sites, sports facilities, pedestrian zones and association premises.

OfficialCannabis Act FAQ

United Kingdom

Reviewed 17 Aug 2026 · UK + devolved

Legal prescribing does not mean routine public-system access.

NHS England and Scotland say very few people are likely to receive a prescription. Unlicensed access depends on an individual specialist decision, and commissioning differs across the UK nations.

OfficialNHS England accessOfficialNHS Scotland accessOfficialCBPM reschedulingOfficialNorthern Ireland access
Topic
CA

Canada

Verified 17 Aug 2026 · Federal + local

DE

Germany

Verified 17 Aug 2026 · Federal

GB

United Kingdom

Verified 17 Aug 2026 · UK + devolved

LAW

Medical status

Is there a lawful medical route?

Legal

A federal medical-access framework operates under the Cannabis Act and Cannabis Regulations.

RegulatorMedical frameworkReg.Cannabis Regulations
Legal

Medical cannabis may be prescribed by a physician and dispensed by a pharmacy.

LawMedCanG §3OfficialMedical FAQOfficialCannabis Act FAQ
Legal, tightly controlled

Cannabis-based products for medicinal use (CBPMs) have a lawful prescription route.

Reg.CBPM RegulationsOfficialCBPM reschedulingOfficialNorthern Ireland access
LAW

Adult-use status

What non-medical possession or access is lawful?

Legal

Adults of the applicable provincial or territorial legal age may buy and possess legal cannabis.

The federal public-possession limit is 30 g of dried cannabis or its equivalent; minimum age and retail rules vary by province or territory.

LawCannabis ActOfficialProvincial rules
Limited legal access

Limited non-commercial possession, home cultivation and cultivation-association access are lawful for adults.

This is not a general commercial retail market: possession is capped at 25 g in public and 50 g at home; home cultivation is capped at three plants.

LawKCanGOfficialCannabis Act FAQ
Illegal

Non-medical cannabis remains illegal.

Cannabis remains a Class B controlled drug; unauthorized possession, supply and cultivation remain offences.

OfficialCBPM reschedulingOfficialControl framework
LAW

Control & scheduling

Which legal control framework applies?

Cannabis is federally controlled through the Cannabis Act and Cannabis Regulations.

That framework separately regulates cannabis products and prescription drugs containing cannabis.

Reg.Cannabis RegulationsRegulatorProduct rules

Cannabis and non-synthetic THC are no longer narcotics under the Narcotics Act.

Non-medical cannabis is governed by KCanG; medical cannabis is governed by MedCanG.

OfficialCannabis Act FAQOfficialMedical FAQLawKCanG

Cannabis is Class B and generally Schedule 1; qualifying CBPMs are Schedule 2.

Products outside the legal CBPM definition remain Schedule 1 unless separately scheduled or authorized.

OfficialControl frameworkOfficialCBPM rescheduling
REGULATION

Medical access

How does a patient obtain a lawful product?

Obtain a medical document, then register with a federally licensed medical seller.

A patient may instead register with Health Canada to produce personally or designate a producer.

RegulatorMedical accessRegulatorMedical framework

A physician prescribes; an operating pharmacy dispenses against that prescription.

Medical cannabis no longer requires the former narcotic-drug legal classification.

LawMedCanG §3OfficialMedical FAQ

Licensed cannabis medicines follow their marketing authorization; unlicensed CBPMs require specialist prescribing.

Public-system access is devolved. NHS England and NHS Scotland both describe routine access as limited to a small number of patients and products.

OfficialCBPM reschedulingOfficialNHS England accessOfficialNHS Scotland accessOfficialNorthern Ireland access
REGULATION

Who can access

Who may use the medical or adult-use pathway?

A health-care practitioner must authorize use; clients of a federal medical seller must ordinarily reside in Canada.

A responsible adult may act for a child, older adult, or person with a serious impairment.

RegulatorMedical accessReg.Cannabis Regulations

The federal prescribing provision does not set a closed list of qualifying conditions.

Treatment is a physician decision; dentists and veterinarians may not prescribe medical cannabis.

Important scope note

Coverage or reimbursement rules are separate from the legal ability to prescribe.

LawMedCanG §3

A specialist may consider an unlicensed CBPM when clinically appropriate; licensed products have product-specific indications.

NHS England guidance highlights severe epilepsy, chemotherapy-related nausea and multiple-sclerosis spasticity for specific medicines; devolved services publish their own access guidance.

OfficialCBPM reschedulingOfficialNHS England accessOfficialNHS Scotland accessOfficialNorthern Ireland access
REGULATION

Prescription

What authorization must the patient have?

The federal medical route uses a signed medical document rather than an ordinary retail prescription.

The document states the authorized daily amount and period of use and supports registration.

RegulatorMedical accessReg.Cannabis Regulations

A physician prescription is required; pharmacies may dispense only on presentation of it.

A government bill would add personal-contact requirements and restrict mail-order supply. It remains a proposal and is not treated here as current MedCanG law.

Important scope note

Proposed rules are shown only as a watch item; the consolidated statute controls the current-law summary.

LawMedCanG §3OfficialPending MedCanG bill

Unlicensed CBPMs must be prescribed by a doctor on the GMC specialist register.

A marketing-authorized medicinal product is not subject to that same additional specialist-only route merely because it is cannabis-based.

OfficialCBPM rescheduling
LAW / POLICY

Visitor & import

Can a visitor bring prescribed cannabis across the border?

Normally prohibited

Do not cross the Canadian border with cannabis, including medical cannabis or CBD, without a Health Canada exemption.

A medical prescription is not Health Canada authorization. CBSA says a permit or exemption is required even when the product is lawful where the trip began.

OfficialBorder rulesOfficial2026 border notice
Confirm before travel

Do not infer a simple visitor exemption from Germany's domestic legalization.

BfArM says certified travel documentation is generally still needed because international controls and other countries' rules continue to apply.

Official evidence unclear

The official page is travel guidance, not a blanket authorization for every foreign product entering Germany.

RegulatorTravel guidance
Conditional

A non-UK resident may carry up to a three-month supply of a Schedule 2–4 Part I medicinal product that was lawfully prescribed and dispensed.

Carry it on your person with a clinician letter. Schedule 1 products cannot normally enter without a licence, so product classification matters.

OfficialBorder rules
REGULATION

Permitted forms

Which product forms are within the regulated pathway?

Federal medical sellers may supply fresh or dried cannabis, edibles, topicals and extracts.

Plants and seeds also support authorized production routes. These cannabis products are not, merely by using the medical pathway, Health Canada-authorized treatments for a disease or symptom.

RegulatorMedical accessRegulatorProduct rulesRegulatorProduct evidence

Medical products include standardized dried flower or extracts and medicines containing dronabinol or nabilone.

Exact preparation availability depends on the prescription and pharmacy supply. Adult-use associations may distribute only marijuana or hashish in pure form, not edibles.

LawMedCanG §3OfficialMedical FAQOfficialCannabis Act FAQ

Licensed examples include an oral CBD liquid, a synthetic cannabinoid capsule and a THC/CBD mouth spray.

Unlicensed CBPMs may take other medicinal forms, but smoking cannabis or a CBPM remains prohibited.

OfficialNHS England accessOfficialCBPM rescheduling
LAW / POLICY

Driving

Does lawful access change drug-driving rules?

Lawful possession or medical authorization does not permit cannabis-impaired driving.

The Criminal Code prohibits driving while impaired to any degree and creates separate offences at federally prescribed blood-THC concentrations within two hours of driving.

LawImpaired-driving lawReg.THC limits

A 3.5 ng/mL blood-serum THC threshold applies to the road-traffic offence.

Section 24a excludes THC arising from proper use of medicine prescribed for a specific case. That exception does not authorize driving while actually unfit under the separate criminal impairment rule.

LawStVG §24aLawStGB §316

A prescription does not permit driving while impaired.

In England, Scotland and Wales, a medical defence may apply to the specified-drug limit offence when medicine was lawfully supplied and taken as directed, but not to impairment. Northern Ireland applies a separate impairment regime.

Important scope note

The per-se drug-limit and medical-defence guidance cited here applies to Great Britain, not Northern Ireland.

OfficialGB driving rulesOfficialNI driving rules
PRACTICAL ACCESS

Practical implications

What changes the real-world ability to access or use cannabis?

Medical registration is resident-based; authorized provincial retail is the practical route for eligible adult visitors already inside Canada.

Public-use and home-cultivation rules can change by province, territory and municipality. Authorized medical patients have separate public-possession documentation and limits.

Reg.Cannabis RegulationsRegulatorMedical frameworkOfficialProvincial rules

There are no general adult-use shops; lawful supply is limited to home grow and non-commercial cultivation associations.

Home cultivation and association membership require at least six months' residence or habitual abode. Public consumption is restricted around minors, youth sites, sports facilities, pedestrian zones and association premises.

OfficialCannabis Act FAQ

Legal prescribing does not mean routine public-system access.

NHS England and Scotland say very few people are likely to receive a prescription. Unlicensed access depends on an individual specialist decision, and commissioning differs across the UK nations.

OfficialNHS England accessOfficialNHS Scotland accessOfficialCBPM reschedulingOfficialNorthern Ireland access

Method: Consolidated law and regulations control legal-status claims. Official guidance explains procedure and practical access; proposals are never treated as current law.

Scope: 6 of 48 seed jurisdictions are published. The remainder are withheld until each claim completes primary-source review.

Use: This is a sourced research aid, not legal advice. Border, local and product-specific rules can change; confirm before acting.

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